DOD's 'Hello, I am a contractor' policy kicks in

Defense Department officials have changed the department’s regulations to require service contractors to identify themselves as contractors, whether in person or in a letter.

DOD issued its final rule May 5, even though there has been an interim rule in effect since September 2010.

The Defense Federal Acquisition Regulation (FAR) Supplement now states that service contractor employees must say they are contractors or be introduced as such in a conversation. Contractors are also required to note who they are “in telephone conversations and informal and formal written correspondence.”

Officials are leaving it up to agency heads to decide exactly how to carry out the new rule.

While open for input from the public, two of the five comments DOD received on the proposal urged officials to clearly lay out whom this policy applies to by setting particular limits. The concerns centered on the possibility of expanding the policy from personal service contractors to employees working on general services contracts.

Personal services contracts can possibly circumvent normal hiring laws, which causes concerns for agencies. A personal services contract is characterized by the employer-employee relationship it creates between the government and the contractor, according to the FAR.

Officials didn’t make changes but said “It is precisely because of the potential for a migration of a ‘general service contract’ into what is effectively a ‘personal services contract’ that the rule is necessary.”

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